Numbering for Machine-to- Machine Communications - ComReg
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Numbering for Machine-to-
Machine Communications
Consultation
Reference: ComReg 13/33
Date: 28 March 2013
An Coimisiún um Rialáil Cumarsáide
Commission for Communications Regulation
Abbey Court Irish Life Centre Lower Abbey Street Dublin 1 Ireland
Telephone +353 1 804 9600 Fax +353 1 804 9680 Email info@comreg.ie Web www.comreg.ieAddressing Machine-to-Machine Communications ComReg 13/33
Legal Disclaimer
This consultation document is not a binding legal document and neither does it contain
legal, commercial, financial, technical or other advice. The Commission for
Communications Regulation is not bound by it, nor does it necessarily set out the
Commission’s final or definitive position on particular matters. To the extent that any
inconsistency might exist between the contents of this document and the due exercise
by it of its functions and powers, and the carrying out by it of its duties and the
achievement of relevant objectives under law, such contents are without prejudice to the
legal position of the Commission for Communications Regulation. Inappropriate
reliance ought not therefore to be placed on the contents of this document.
Page 2 of 39Addressing Machine-to-Machine Communications ComReg 13/33
Content
Section Page
1 Introduction .......................................................................................... 6
2 Background.......................................................................................... 7
3 Numbering and Addressing ............................................................... 11
3.1 E.164 telephone numbering for M2M ............................................................. 11
3.2 National consideration of M2M numbering ..................................................... 13
3.3 ComReg’s View .............................................................................................. 14
3.4 M2M & E.212 .................................................................................................. 17
3.5 Number Portability & Block Re-allocation in the M2M environment ................ 18
3.6 The practicality of switching service provider ................................................. 20
3.6.1 Shared MCC and National Roaming ......................................................... 20
4 Regulatory Impact Assessment (RIA) ............................................... 22
5 Next steps .......................................................................................... 23
Page 3 of 39Addressing Machine-to-Machine Communications ComReg 13/33
Annex
Section Page
Annex: 1 Legal basis......................................................................................... 25
Annex: 2 NRAs which have developed an M2M policy .................................... 30
Annex: 3 Proposed Changes to National Numbering Conventions .................. 31
Annex: 4 Numbering Advisory Panel Feedback regarding M2M Numbering ... 36
Annex: 5 Abbreviations ..................................................................................... 37
Page 4 of 39Addressing Machine-to-Machine Communications ComReg 13/33
Table of Figures
Figure Page
Figure 1: M2M generic application process ...................................................... 8
Figure 2: M2M Value chain – interplay of roles ................................................. 8
Figure 3: Global M2M Connections, from 2010 to 2020. .................................. 9
Page 5 of 39Addressing Machine-to-Machine Communications ComReg 13/33
1 Introduction
1 Machine to Machine (M2M) refers to technologies that allow both wireless and
wired systems to communicate with other devices of similar ability. M2M
communication is growing rapidly, driven in no small part by the expansion of
next generation telecommunications technology and a decline in the cost of the
embedded wireless modules and sensors that enable M2M services. This
continued improvement in the infrastructural environment around M2M has led to
a rapid growth of applications and services that meet users’ business and
lifestyle needs. M2M communications are already deployed in Ireland. These
deployments are based on existing numbering/addressing resources whose use
for this purpose could not have been seen. It seems prudent, if not essential that
a more targeted long term numbering resource designed specifically for M2M
purposes should be made available to satisfy the demand for numbers arising
from the emerging M2M services.
2 Section 2 of this document gives background on M2M outlining progress to date
and its predicted benefits and deployments in the future,
3 Section 3 of this document discusses key issues regarding M2M numbering and
addressing, where ComReg presents its proposals. ComReg does not consider
that the proposals within this document give rise to the need for a Regulatory
Impact Assessment ('RIA') as described in Section 4, and ComReg presents the
Next Steps in Section 5.ComReg’s statutory functions, as set out in the
Communications Regulation Act 2002, as amended, are detailed in Annex: 1.
Those statutory obligations and functions provide the legislative framework
under which ComReg operates and are therefore of fundamental importance to
ComReg’s decision making process, to its Consultations, to its Responses to
Consultations and to its Decisions.
4 Annex 2 provides relevant information from other European countries with
regards to decisions made in respect of M2M and numbering matters.
5 Annex 3 outlines ComReg's proposed changes to the Numbering Conventions
based on proposals presented in this document, that have been built on
discussions/correspondence held within ComReg’s Numbering Advisory Panel,
and on responses to an exploratory questionnaire as presented in Annex 4.
Page 6 of 39Addressing Machine-to-Machine Communications ComReg 13/33
2 Background
6 The basic building block of the Internet of Things is machine-to-machine
communication (M2M), in which devices communicate directly with one another
with minimal or no human intervention. Different networking technologies can be
used to connect M2M devices, depending on the amount of mobility needed,
quality required, data rate, Duty Cycle and the degree of dispersion of devices
over an area 1. Mobile wireless is a technology suited for many applications,
whilst fixed-line communications are also suited in cases where mobility is not
essential and where physical access between devices is not a problem.
7 Applications deployed using M2M have so far been relatively specialised in
nature, though this may change as the market and services evolve, with parties
considering M2M as a potential source of new revenue and/or as a means of
creating efficiencies and cost savings. For example, it has been reported that a
main driver of M2M adoption in Europe will be the automotive industry. From
2015 all newly registered motor vehicles will need to be equipped with an eCall
emergency call system and car manufacturers are expected to integrate
embedded SIMs in order to meet these requirements2.
8 The importance of the M2M debate figures prominently in the views of many
market futurists, for example;
• The GSMA forecasts a connected universe of up to 50 billion connected
devices by 2020 3, and GSMA reiterated the important role M2M will play in
the future of communications at its annual GSMA Mobile World Congress 4,
• Analysys Mason 5 predicts that the global market for M2M device
connections will grow from 62 million devices in 2010 to 2.1 billion devices in
2020 6. With an estimated year-on-year growth rate of 36% - 52%, M2M
seeks to be one of the fastest-growing connectivity sectors in the next
decade, and
1
http://oecdinsights.org/2012/01/31/the-internet-of-things/
2
2013 M2M predictions from Jürgen Hase, VP of M2M Competence Center at Deutsche Telekom and
Chairman of the M2M Alliance - See http://www.fiercewireless.com/europe/press-releases/2013-
m2m-predictions-j-rgen-hase-vp-m2m-competence-center-deutsche-telekom#ixzz2F1DzKTGV
3
GSMA article published 3 October 2012, http://www.gsma.com/mobilefordevelopment/the-other-
m2m-opportunity-enhanced-utility-access-in-emerging-markets
4
http://www.gsma.com/newsroom/gsma-the-rise-of-connected-devices-will-drive-mobile-operator-
data-revenues-past-voice-revenues-globally-by-2018#.UTnALM1bduI.email
5
http://www.analysysmason.com/Research/Content/Reports/RRE02_M2M_devices_forecast/
6
GSM World Website: “GSMA Outlines Potential for Embedded Mobile: Enabling a World of
Connected Devices”; February 15, 2010. Http://www.gsmworld.com/newsroom/press-
releases/2010/4635.htm
Page 7 of 39Addressing Machine-to-Machine Communications ComReg 13/33
• GE estimates 7 that the "Industrial Internet" has the potential to add $10-15
trillion (€7.7-11.5 trillion) to global GDP by 2030 and reduce billions of dollars
of waste across major industries such as healthcare, energy and
transportation. While this recent report is primarily focused on the impacts on
heavy industries (aviation, energy etc.) it does also cover a range of other
sectors 8.
9 The following graphics, Figure 1 and Figure 2 from Informa Communications3,
show what a typical M2M application consists of and how the roles in a typical
application may be broken down.
Figure 1: M2M generic application process
Figure 2: M2M Value chain – interplay of roles
10 The hardware devices that provide the input signals to an M2M application and
the output alerts or actuation, will typically take the form of sensors, actuators of
some sort and/or visual presentations of monitored material. The latter could for
instance be provided by building security cameras or personal alarm systems for
elderly or incapacitated people.
7
GE report, published 26 November 2012, http://files.gereports.com/wp-content/uploads/2012/11/ge-
industrial-internet-vision-paper.pdf
8
Techcentral article published 27 November 2012, http://www.techcentral.ie/20386/industrial-internet-
to-add-trillions-to-global-gdp-by-2030#ixzz2FJBPYbS0
Page 8 of 39Addressing Machine-to-Machine Communications ComReg 13/33
11 Machina Research has provided market forecasts for Ireland for M2M
connections from 2010 to 2020, as shown in Figure 1 9, which predicts that there
will be 25 million M2M connections in Ireland by 2020.
Figure 3: Global M2M Connections, from 2010 to 2020.
9
Extracted from a slide pack of a presentation by Machina to ComReg, August 2012.
Page 9 of 39Addressing Machine-to-Machine Communications ComReg 13/33
12 As shown in Figure 1, analysts predict that in the medium-to-long term, about
one third of M2M applications will run on mobile networks. The balance will be
on fixed networks or Short Range Devices, or possibly make use of some other
form of wide area wireless network solution. Some service providers and
manufacturers propose the setting aside of dedicated radio spectrum for this
purpose, whilst others such as Neul in the UK propose the use of UHF white
space spectrum for M2M. ComReg's policy is to address spectrum-related
issues in line with the work programme it sets out in its Spectrum Management
Strategy. The current Strategy (Document 11/89 10) covers the period 2011 -
2013. It is intended that the next Spectrum Management Strategy will consider
spectrum management issues related to M2M. Interested parties will be
welcome to make submissions at that time to assist ComReg in determining the
spectrum related priorities for the near and medium future.
13 Ireland's current SRD framework is also of interest given that it allows for
operation, on a licence-exempt basis, many different types of short-range
applications across a wide variety of frequency bands. This for example
includes M2M applications such as Road Transport and Traffic Telematics
(RTTT), RFIDs, tracking, tracing and data acquisition and Active Medical
Implants (AMI). Different power limits and operational requirements apply,
depending on the frequency band of operation. These operational requirements
are detailed in ComReg’s SRD document 02/71R6 11.
14 Smart metering is an example of an M2M application gaining much attention
currently. Smart meters are electronic devices capable of measuring energy
consumption and providing real time information to the customer on usage and
costs. In Ireland a National Smart Metering Programme (NSMP) is already
underway, championed by the Commission for Energy Regulation (CER). The
NSMP is currently in its second phase, with the CER having recently published
an Information Paper and a number of reports12 on the programme’s status and
plans.
15 Smart metering technologies have taken advantage of spectrum available within
the main unlicensed radio bands, including 2.4GHz, 868MHz, 434MHz and
169MHz.Use of spectrum in these bands is subject to application for a test or
trial licence 13 and approval from ComReg.
11
Document published 19 December 2011, see
http://www.comreg.ie/_fileupload/publications/ComReg0271R6.pdf
12
GE report, published 26 November 2012, http://files.gereports.com/wp-
content/uploads/2012/11/ge-industrial-internet-vision-paper.pdf
13
For information on Test and Trial Ireland see www.testandtrial.ie
Page 10 of 39Addressing Machine-to-Machine Communications ComReg 13/33
3 Numbering and Addressing
16 M2M communications solutions are already in operation in Ireland utilising
existing national numbering ranges and addressing resources, a situation that
has been sufficient heretofore. Continuing use of these existing numbering
resources for the potentially very many M2M applications that may emerge in the
coming years could put an undue strain on the existing supply of numbers, whilst
reducing capacity for other more established communications services. ComReg
considers it timely to investigate the possibility of a more targeted long term
numbering resource for the exclusive use of M2M applications and services. This
section considers specific numbering solutions for M2M applications.
3.1 E.164 telephone numbering for M2M
17 M2M applications require networks capable of long range connectivity including
coverage across national borders, ubiquitous coverage and flexible scalability.
Internet Protocol version 6 (IPv6) addressing has potential as a long term
solution for addressing M2M devices but E.164 numbering 14 appears to be
preferred by operators and M2M service providers in the short to medium term,
as it leverages the existing capabilities (billing, routing, authentication etc.) of
fixed and mobile networks.
18 While E.164 numbering can offer relatively simple implementation within current
network infrastructures, the potential number of M2M devices to be
accommodated is huge and this implies a need for very large number blocks to
address M2M devices. In many European countries, including Ireland, there is a
real risk that existing numbering ranges will be unable to provide sufficient
numbering capacity for M2M applications while also meeting traditional
numbering demands. Rapid exhaustion of E.164 number ranges could therefore
occur and it is appropriate for ComReg to address this issue in an expedited
manner. Other European countries have already created specific number ranges
with large capacity for exclusive use by M2M 15.
19 The issue of numbering and addressing for M2M devices has been discussed
and deliberated upon at various international fora including WG NaN16.
20 In 2010, the ECC published a report 17 in which it considered a number of options
to address the M2M challenge. This report drew the following conclusions:
14
The international public telecommunication numbering plan, http://www.itu.int/rec/T-REC-E.164/en
15
See Annex 2
16
The Electronic Communications Committee (ECC) Working Group on Numbering and Networks
17
ECC Report 153 available at http://www.erodocdb.dk/Docs/doc98/official/pdf/ECCREP153.PDF
Page 11 of 39Addressing Machine-to-Machine Communications ComReg 13/33
• The expected annual growth rate of required M2M numbers over the period
2010 to 2020 is approximately 20%;
• In the longer term, IPv6 addressing will become important as an alternative
numbering resource for M2M applications. However, there is great
uncertainty about how long this will take and therefore M2M numbering
policy should be flexible enough to act as a longer term solution;
• A significant number of CEPT countries have insufficient capacity within their
existing numbering plans to accommodate numbering requirements for M2M
applications; and
• A complete harmonised approach on possible M2M numbering solutions is
not needed in Europe.
21 The report also presented four numbering options for M2M applications:
(1) Use existing mobile number ranges;
(2) Use a new number range;
(3) Use an international numbering solution; or
(4) Use network internal numbers.
22 In the short to medium term, the use of all options can be envisaged. In cases
where there is a need to distinguish M2M services from traditional mobile
services, Option (1) has to be excluded. Options (2) and (4) are needed if the
growth of M2M is larger than expected or if adequate capacity does not exist.
Option (3) would require a co-ordinated international approach led by the ITU.
23 In May 2011, the ECC made a recommendation (ECC Recommendation
(11)03 18), which set out (amongst other things) that;
• National Regulatory Authorities (NRAs) should establish numbering solutions
for M2M applications as part of the national numbering plans;
• A long term solution is IPv6 or numbers/addresses other than E.164
numbers should preferably used for M2M applications;
• NRAs should consider opening up new number ranges for M2M applications;
• Number length should be as long as possible (maximum of 15 digits for
E.164 numbers); and.
• the NRA should ensure that the new number range(s) are not used as an
alternative to existing number ranges to escape regulatory requirements
18
ECC Recommendation (11)03 - Numbering and Addressing for Machine -to Machine (M2M)
Communications, published 5 May 2011.
Page 12 of 39Addressing Machine-to-Machine Communications ComReg 13/33
3.2 National consideration of M2M numbering
24 In early 2012 ComReg circulated a questionnaire to its Numbering Advisory
Panel19 to ascertain the panel’s views on the M2M numbering challenge. The
questionnaire was tightly scoped, being focused solely on the numbering
aspects and on inter-operator/cross-border issues, such as routing and billing.
Responses to the questionnaire are summarised in Annex: 4 and discussed
below.
25 NAP members generally believe that existing mobile, geographic and non-
geographic numbers should not be used for M2M applications. Reasons for this
include:
• A risk of exhausting the existing ranges;
• In the case of non-geographic and existing PRS numbers, limitations on
access from overseas; and
• Inter-operator billing difficulties and a risk of incurring unnecessary expense.
26 In the main, NAP members accept that a need could arise for alternate M2M
services and business models in practice, though there was some reluctance to
the use of the existing 15XX Premium Rate Service (PRS) ranges. Given that it
is not possible to predict business models or interconnection regimes which may
be implemented in the future in M2M with premium rate (e.g. one time
transaction based services as opposed to subscription type M2M services)
transactions. This led to a universal preference from NAP for the designation of a
new M2M range or ranges, rather than rely on existing voice-oriented ranges.
27 Most respondents also preferred nomadic ranges for M2M purposes.
28 It was unclear from questionnaire responses whether a single range or multiple
ranges was preferred. ComReg is conscious that there may be numerous
benefits in initially designating different sub-ranges for different services. This
could be beneficial for users of M2M from a routing and billing perspective, whilst
also being administratively simpler for ComReg to manage the different sub-
ranges.
29 For instance, if 077 is the overall M2M range then;
• 077-1 could be designated for fixed-line services;
• 077-7 for mobile services; and
19
The NAP is a specialist committee that provides guidance to ComReg on key issues concerning
numbering policy and number management.
Page 13 of 39Addressing Machine-to-Machine Communications ComReg 13/33
• 077-9Y for alternative M2M services (where ‘Y’ indicates the specific sub-
range).
To avoid risk of exhaustion, 077-2 could then be reserved for expansion of fixed-
line services and 077-8 for expansion of mobile services.
30 NAP members diverged on the number of digits to be used for M2M numbers,
with some preferring use of the maximum number length that would not result in
cross-border difficulties and others preferring to maintain the current number
lengths in use in Ireland.
31 There was consensus that regulatory obligations concerning access to
emergency services and number/service portability need to be addressed.
32 While most NAP members felt that there is no absolute urgency to address M2M
numbering at this moment, it was also recognised that any procrastination could
lead to longer term problems. The prevailing risk remains that in absence of
targeted action now any proliferation of M2M services on existing voice numbers
could deplete that numbering resource, subsequently resulting in very costly
disruption and a difficult and costly task of migrating large numbers of developed
M2M services onto a new range.
3.3 ComReg’s View
33 ComReg proposes to address the issue of a new M2M numbering range sooner
rather than later, given the risks described above and ECC recommendations on
same. In that respect it is ComReg's view that action should be taken
immediately to mitigate the risk that any sudden snow-balling demand for
numbers from the M2M sector could drive future number changes that might
adversely impact ordinary consumers or M2M services, or both.
Q. 1 Do you agree with ComReg that a new number range for M2M should be
introduced as soon as possible? Please set out the reasons for your answer.
Page 14 of 39Addressing Machine-to-Machine Communications ComReg 13/33
34 There has been broad discussion on whether or not separate ranges are
required for different types of M2M applications. It is ComReg’s preliminary view
that a single M2M range will provide sufficient capacity for future M2M
applications. ComReg cannot predict future business models or interconnection
regimes, therefore considers it prudent to initially breakdown such a dedicated
M2M range into a limited set of sub-ranges (e.g. 077-1+ and 077-2+ for mobile
initially and 077-8+ and 077-7+ for fixed applications); the use of 077-9+ as an
option for premium M2M numbers could also be considered (subject to
discussions below). This could provide efficiencies with respect to routing and
billing for users. ComReg could review practicalities and usage patterns on a
periodic basis, and these sub-range distinctions could be allowed to lapse in
time, if found to be unnecessary.
Q. 2 Do you agree with ComReg’s preliminary view that an overall single M2M range
will adequately meet the needs of all M2M providers whether fixed or mobile,
and with the use of lead digits to distinguish between fixed and mobile (at least
until review)? Please set out the reasons for your answer.
35 With regard to number length, ComReg considers that the new number range
should be as long as is reasonable. This would avoid the need for future
expansion of the range to meet a later scarcity of capacity. According to ITU-T
recommendation E.164, the maximum permissible number length is 15 digits,
which would include the ‘353’ country code for Ireland. As these numbers are
destined to be embedded in M2M firmware or software the number of digits
should not pose any practical problems. If a 2-digit access code, for ComReg’s
preferred range of +353-77, is used (or 077 if dialled internally in Ireland), then
10-digit subscriber numbers are possible for M2M purposes.
36 A 10-digit subscriber number 20 (i.e. maximum length, allowing for our 3-digit
country code) would provide 10 billion numbers for M2M use. This is two digits
longer than the longest existing subscriber number range in Ireland at present
(i.e. the mobile number range used to access voicemail services 21). As
highlighted in Annex 2, other EU countries that have already designated number
ranges for M2M have generally adopted a 10 or 11 digit format for their M2M
subscriber numbers, leading to national capacities of 10 or 100 billion M2M
numbers, respectively.
20
The subscriber number is the part that follows the country code and area (or network) code
21
Voicemail services are now predominantly accessed by dialling 171 regardless of service provider.
Before this common approach was used voicemail was accessed by dialling the subscriber’s mobile
number with a preceding digit “5” in the digit sequence for the subscriber part of the number. For
example, to access the voicemail number of 087 1234567 one would dial 087 51234567. This is the
longest subscriber number range currently operational in Ireland. ComReg’s proposal is to introduce
an M2M range that is two digits longer.
Page 15 of 39Addressing Machine-to-Machine Communications ComReg 13/33
37 ComReg proposes to precede this 10 digit subscriber number by a two digit
access code, preferably the code 77 (i.e. resulting in a nationally-dialled number
of 077-123 456 7890 after trunk prefix ‘0’ is added 22)). As this lies adjacent to
the 076 range - used for IP-based and nomadic services - in the numbering plan,
recognition of the ‘special’ nature of both ranges may be facilitated (where
‘special’ refers to non-standard characteristics)
Q. 3 Do you agree with ComReg’s proposal to introduce a number range in the
format 077-123 456 7890, thereby providing ten billion numbers for M2M
applications? Please state the reasons for your answer.
38 The standard 23 block size for number allocations is 1000 for geographic and
non-geographic numbers and 100,000 for mobile numbers. As can be seen from
Machina's predictions in Figure 1, one third of M2M connections are expected to
be mobile, with a minority using fixed-line solutions. Given that there is expected
to be far more mobile devices, ComReg considers that the minimum block size
for M2M allocations should initially be 100,000 for qualifying mobile applicants
and 10,000 for qualifying fixed-line applicants. Doing so should afford practical
and administrative efficiency for M2M users and ComReg.
Q. 4 Do you agree with ComReg’s preliminary view that the standard block size for
M2M numbers should initially be 100,000 for qualifying mobile applicants and
10,000 for qualifying fixed-line applicants? Please give reasons for your
answer.
39 M2M PRS could potentially also emerge, as recognised by the NAP and
numbering needs to be available for those. PRS, typically content services in
nature, are inherently price dependent and the selected number range for any
PRS service is actually a mechanism by which charging for that specific content
occurs. In the M2M world, ComReg foresees PRS usage as being once off,
transaction based services. For example, when services are required
sporadically (e.g. for updating software in a car) rather than on a regular basis
(where a subscription based business model may be appropriate), M2M PRS
could allow for such sporadic and infrequent communications via a specific
numbering range.
22
If dialled internationally, this number would be presented as +353-77-123 456 7890.
23
ComReg would reserve the right to allocate larger blocks (e.g. 1M numbers) in exceptional cases;
for example if a strong case was made by a very large manufacturer, such as an auto manufacturer.
Page 16 of 39Addressing Machine-to-Machine Communications ComReg 13/33
40 NAP oppose the usage of capacity in the existing 15XX PRS number ranges
(above),for M2M purposes. ComReg agrees with NAP that this number range is
not appropriate as it does not allow for international access. It is ComReg’s
preliminary view that if M2M premium rate services emerge in the future this
need can ideally be met from the proposed 077-9Y range (discussed above),
which is 15 digits in length in total including country code and access code.
Q. 5 Do you agree with ComReg’s view that any emerging M2M premium rate
services should be accommodated using the proposed 077-9Y range?
Please provide reasons for your views.
Q. 6 Do you agree with ComReg that if new PRS M2M number ranges are to be
assigned, only a limited number of these is needed (e.g. 3 per-minute and 3
per-call number ranges)? Please set out the reasons for your answer.
3.4 M2M & E.212
41 ITU Recommendation ITU-T E.212 24 defines a unique international identification
plan for public fixed and mobile networks providing users with access to public
telecommunication services. The E.212 identification plan was originally
developed for use in public land mobile networks (PLMN) to identify
geographical areas, networks and subscriptions.
42 E.212 numbering uses a 15 digit decimal string called the international mobile
subscription identity (IMSI). Every SIM card in every mobile device in the world
has a unique IMSI number which is used to identify the home country, the home
network and the subscriber attached to that network. The IMSI consists of three
fields:
i. Mobile Country Code (MCC) – The MCC identifies the country where the
mobile network is located. The MCC for Ireland is 272.
24
Recommendation ITU-T E.212 - The international identification plan for public networks and
subscriptions – Available at: www.itu.int
Page 17 of 39Addressing Machine-to-Machine Communications ComReg 13/33
ii. Mobile Network Code (MNC) – The MNC identifies a mobile network in a
particular country. For example, the MNC for Vodafone in Ireland is 01. So
272-01 identifies Vodafone’s network in Ireland. ComReg administers the
allocation of MNCs in Ireland as part of its numbering plan management
function. According to the E.212 recommendation, MNCs are only to be
assigned to, and used by, public networks offering public
telecommunication services.
iii. Mobile Subscription Identification Number (MSIN) – The MSIN is the
third field of the IMSI. It is up to 10 digits in length, and is administered by
the relevant operator to identify individual subscriptions on its network.
43 Utilising mobile networks for M2M services will require each communicating
M2M device to have the capability to attach to an available mobile network,
thereby requiring SIM functionality in all addressable M2M devices. This raises
some challenges in the context of number portability and switching between
service providers.
3.5 Number Portability & Block Re-allocation in the M2M
environment
44 In conventional mobile devices, mobile customers can easily switch between
underlying service providers by changing the SIM card in their device.
Regulatory procedures are also in place to ensure that a subscriber can keep its
existing mobile telephone number, albeit on a new SIM card with a different IMSI
to identify the new service provider’s underlying network.
45 In the M2M environment where a customer may have thousands or even tens of
thousands of widely dispersed devices 25, switching SIM cards in order to change
service provider is not a viable solution given the cost, effort and timescale
involved in visiting each device. The promotion of competition is a regulatory
objective to ensure a vibrant market in M2M services and other solutions are
needed to avoid “operator tie-in”. These require M2M devices to have IMSI
numbers that are independent of the underlying mobile network operators.
46 A wide range of M2M applications is emerging. These include utility Smart
Metering for which there is a single customer (i.e. the utility company) but with
potentially millions of end user devices. Under current arrangements, if the utility
company wishes to change network operator (e.g. for commercial reasons) it
would need to change the SIM cards in millions of devices. That is clearly not a
practical solution, as every smart meter would need to be visited to have its SIM
swapped out.
25
Such as smart metering or eCall applications.
Page 18 of 39Addressing Machine-to-Machine Communications ComReg 13/33
47 Given the nature of M2M applications there may not be the same need to ensure
that numbers can be ported when switching service providers. The National
Numbering Conventions 26 provide for the situation in which a large contiguous
block of numbers can be re-assigned from one operator to another, at the
request of the number-holder, provided the applicant is the sole user of that
block. While such moves are expected to be very rare, it is important that an
M2M Service Provider (SP) can efficiently move its services from an
unsatisfactory operator to one that better meets its needs, without the necessity
to initiate large numbers of ports. For historical reasons27, the relevant
Convention only speaks of fixed-line customers but ComReg considers that
limitation should be removed.
Q. 7 Do you think there is a need to provide for number portability for the M2M
communications market? Please give reasons for your answer.
Q. 8 Do you consider that the block re-allocation process described above (and
covered by Numbering Convention 10.5-4) is adequate to meet the needs of
M2M SPs who wish to move all of their services from one network operator to
another? Is this process more appropriate for M2M than number portability or
are both needed? Please give reasons for your answer.
Q. 9 Do you agree that the National Numbering Convention 10.5-4 should be
amended 28 by rewording it to support number block re-allocation for all large
number blocks, regardless of technology (i.e. principally by removing the
reference to “fixed-line” in the Convention)? Please give reasons for your
answer.
26
See http://www.comreg.ie/_fileupload/publications/ComReg1117.pdf
27
The Convention, which was adopted before full mobile number portability was introduced will be
reconsidered in the course of a review of the conventions to be conducted during 2013.
28
Note: While this issue comes to the fore within the current M2M consultation, ComReg considers
that the proposed change also has relevance for other services.
Page 19 of 39Addressing Machine-to-Machine Communications ComReg 13/33
3.6 The practicality of switching service provider
48 To achieve economies of scale, the manufacturers of M2M devices would
undoubtedly prefer to install the M2M identification functionality at the point of
manufacture and not have to provision country-specific SIM modules after
devices reach their national points of distribution in the marketplace. A number
of different solutions could be considered to meet this need and to facilitate more
seamless switching between service providers. These possible solutions are
described in 3.6.1..
49 MNCs are administered by the national numbering plan administrator within each
country in accordance with the principle in Annex B of the ITU-T Rec. E.212.
This Annex B states the principles for the assignment of mobile network codes
(MNCs) within geographic MCCs. According to ITU-T Recommendation E.212
MNCs are only to be assigned to, and used by, public networks offering public
telecommunication services.
3.6.1 Shared MCC and National Roaming
50 The ITU designated the MCC 901 as a shared MCC. This allows for the
provision of Mobile Network Codes (MNCs) that are not tied to any one national
market. Service providers that qualify for an MNC under MCC 901 are able to
operate cross-border services using a single SIM with a single price for data
connectivity.
51 Some M2M providers appear to have found this approach to be beneficial, as it
allows SIM functionality to be configured in devices at the point of manufacture.
It also allows M2M providers to negotiate agreements with several mobile
network operators on either a national or an international roaming basis.
52 This approach requires some co-ordination at the international level with the ITU.
Efficient management of such a scheme might best be handled by the direct
allocation of MNCs and their own blocks of numbers to such very large entities.
Q. 10 Do you agree that a Shared MCC+MNC provides an acceptable and practical
solution to the problem of operator tie-in while also meeting the need for
economies of scale in the manufacture and distribution of M2M devices?
Please set out the reasons for your answer.
Page 20 of 39Addressing Machine-to-Machine Communications ComReg 13/33
53 M2M operators could be at something of a disadvantage by not having MNCs
when seeking to negotiate commercial contracts with mobile providers. Acquiring
its own MNC (whether a national MNC or a shared international one), could
provide more negotiating power to M2M operators when agreeing contracts with
mobile providers and in relation to roaming agreements. Such agreements could
facilitate commercially viable communications coverage within remote regions.
M2M SPs equipped with their own MNCs could be better placed to complete
viable roaming agreements with as many different mobile providers as
necessary to achieve full coverage at competitive prices.
54 Opening up access to MNC’s could stimulate competition by enabling balanced
negotiations that promote the growth of M2M. A large M2M SP holding its own
MNC could have more leverage when entering negotiations with a potential
partner MNO over its roaming (and other) rates. As it would no longer be
dependent on the specific package that a mobile operator is prepared to offer,
but could change SIM and other settings over the air, competition in the
marketplace for M2M would be enhanced. Furthermore, switching to a new MNO
at any stage would be much simpler and less costly for an M2M SP because the
SIM cards themselves that are installed in the M2M devices would not need
replacing.
55 The Netherlands has raised 29 with ITU-T the question of whether large
organisations should be provided with their own MNCs for M2M purposes and it
is clear that this is an issue also being considered in other countries.
56 The ITU recently held a consultation on the "Possibility of parallel usage of 2 and
3 digit E.212 Mobile Network Codes (MNCs) under one geographic Mobile
Country Code (MCC)", with its formal position yet to be finalised. In any case,
ComReg is guided by the rules and recommendations outlined by the ITU in
these matters. Should the ITU recommend the issuing of MNCs to such M2M
organisations and change the criteria as currently stipulated in Annex B of the
ITU-T Rec. E.212, ComReg will duly accordingly consider the matter of making
such MNCs available.
Q. 11 If the ITU decide to permit M2M SPs access to MNCs, do you believe that
ComReg should directly allocate MNCs and M2M numbers to very large M2M
SPs? What is a minimum threshold (i.e. number of M2M applications) that
ComReg could require an SP to utilise to justify access to such a MNC? Please
provide reasons for your answer.
29
Contribution by Netherlands to ITU-T STUDY GROUP 2: “Machine-to-Machine consequences for
number resources E164 and E212”
Page 21 of 39Addressing Machine-to-Machine Communications ComReg 13/33
4 Regulatory Impact Assessment (RIA)
57 ComReg has considered the need for a RIA during the development of this
consultation document and concluded that one is not necessary or appropriate.
58 Firm decisions are proposed only in respect of numbering for M2M. In that
respect, ComReg has a responsibility under legislation 30 to ensure that adequate
numbers and number ranges are provided for all publicly available electronic
communications services. ComReg is also required to set down conditions to be
attached to the Rights of Use for numbers31, including the designation of service
for those numbers, and that obligation also covers M2M numbers. Carrying out
this consultation process is a direct response to meeting those obligations in the
most effective manner.
59 ComReg will have due regard to all views expressed before arriving at its
decisions. It is not anticipated that any such decisions, which are aimed at
facilitating a still developing market, will have a major effect on any actor.
60 ComReg‟s published RIA Guidelines59 (Doc 07/56a), in accordance with a policy
direction to ComReg60, state that ComReg will conduct a RIA in any process that
may result in the imposition of a regulatory obligation, or the amendment of an
existing obligation to a significant degree, or which may otherwise significantly
impact on any relevant market or any stakeholders or consumers. However, the
Guidelines also note that in certain instances it may not be appropriate to
conduct a RIA and, in particular, that a RIA is only considered mandatory or
necessary in advance of a decision that could result in the imposition of an
actual regulatory measure or obligation, and that where ComReg is merely
charged with implementing a statutory obligation then it will assess each case
individually and will determine whether a RIA is necessary and justified.
61 In this Consultation, ComReg considers that it is not imposing a discretionary
regulatory obligation but is acting under a statutory obligation imposed on it by
legislation, as described above.
30
See Annex: 1, and especially A1.8 and A1.9
31
Authorisation Regulation 14(1)
Page 22 of 39Addressing Machine-to-Machine Communications ComReg 13/33
5 Next steps
62 ComReg has put forward a number of specific proposals in this document for
consideration by interested parties and now invites feedback that will help to
guide it on steps it should take regarding M2M and the associated numbering
issues that arise. The responses will be taken into account in ComReg's
Response to Consultation document which will be published following analysis of
all submissions made.
63 The next steps regarding ComReg's numbering proposals are expected to
include any assignment of M2M number ranges that may be designated, along
with the subsequent updating of:
(a) the National Numbering Conventions;
(b) ComReg’s Numbering Applications Document; and
(c) ComReg’s Numbering Status Report.
64 The consultation period will run from 28 March 2013 to 9 May 2013.
65 Responses must be submitted in written form (post or email) to the following
recipient, clearly marked “Submissions to ComReg 13/33”:
Ms. Sinéad Devey
Commission for Communications Regulation
Irish Life Centre
Abbey Street
Freepost
Dublin 1
Ireland
Phone: +353-1-8049600
Email: marketframeworkconsult@comreg.ie
66 All comments are welcome; however it will make the task of analysing responses
easier if comments are referenced to the relevant question numbers from this
document. In all cases please provide reasons in support of your views.
67 As all responses will be published, those submitted electronically must be
unprotected, to facilitate online publication. In submitting any response, please
also set out your reasoning and supporting information for any views expressed.
Page 23 of 39Addressing Machine-to-Machine Communications ComReg 13/33
68 Finally, it may be necessary for respondents to provide confidential information
in their submissions. Confidential information must be clearly identified as such.
ComReg will publish all of the responses it receives to this consultation, subject
to its guidelines on the treatment of confidential information 32.
32
See Document 05/24 at http://www.comreg.ie/_fileupload/publications/ComReg0524.pdf
Page 24 of 39Addressing Machine-to-Machine Communications ComReg 13/33
Annex: 1 Legal basis
Policy Objectives
A1.1. The policy objectives set down for ComReg in the Act of 2002 33 form the
background against which its decisions are taken.
A1.2. In exercising its functions in relation to the electronic communications sector,
ComReg is required to have regard to those statutory objectives as set out in
Section 12 of the Communications Regulation Act, 2002. These objectives
require ComReg:
• To promote competition;
• To contribute to the development of the internal market;
• To promote the interests of end-users within the Community; and
• To ensure the efficient management and use of the radio spectrum and
numbers from the national numbering scheme in the State.
A1.3. In working towards these objectives, the Act provides guidance as to the
principles that ComReg is required to follow to meet these objectives. In the
context of the numbering proposals currently under review, only a subset of
the full list of measures is relevant. Some could be relevant in respect of the
trans-national aspect of certain M2M services. The following extracts have
been taken from Section 12 of the Act, which states34:
A1.4. In relation to the objectives referred to in subsection (1)(a), the Commission
shall take all reasonable measures which are aimed at achieving those
objectives, including- :
(a in so far as the promotion of competition is concerned:
(i) ensuring that users, including disabled users, derive maximum benefit in
terms of choice, price and quality;
(iv) encouraging efficient use and ensuring the effective management of radio
frequencies and numbering resources.
(b) in so far as contributing to the development of the internal market is
concerned—
(i) removing remaining obstacles to the provision of electronic
communications networks, electronic communications services and
associated facilities at Community level,
(ii) encouraging the establishment and development of trans-European
networks and the interoperability of transnational services and end-to-end
connectivity,
33
Communications Regulation Act, 2002
34
See Section 12(2) of the Communications Act 2002 for full listing
Page 25 of 39Addressing Machine-to-Machine Communications ComReg 13/33
(c) in so far as promotion of the interests of users within the Community is
concerned:
(iii) contributing to ensuring a high level of protection of personal data and
privacy,
(iv) promoting the provision of clear information, in particular requiring
transparency of tariffs and conditions for using publicly available electronic
communications services,
(v) encouraging access to the internet at reasonable cost to users, and
(vii) ensuring that the integrity and security of public communications networks
are maintained.
A1.5. Regulation 12(5) of the Act states that in carrying out its functions, the
Commission shall have regard to international developments with regard to
electronic communications networks and electronic communications services,
associated facilities, postal services, the radio frequency spectrum and
numbering. Regulation 12(6) requires ComReg to support technological
neutrality while exercising its functions aimed at achieving the above
objectives.
Numbering and Number Allocation
The majority of the proposals put forward by ComReg in this document relate to
numbering and therefore the following regulations are relevant:
A1.6. The National Numbering Scheme is 35 “… the scheme administered by the
Regulator which sets out the sequence of numbers or other characters which
must be used to route communications to specific locations, terminals,
persons or functions on public electronic communications networks”.
A1.7. Framework Regulation 20(4) establishes that it is an offence for anyone other
than ComReg to assign numbers from the scheme, unless those numbers
have been specifically allocated to them by ComReg (i.e. secondary allocation
of numbers allocated to network operators by ComReg to their own customers
is permitted and normal).
A1.8. Framework Regulation 20 assigns specific responsibilities to ComReg in
respect of the numbering scheme. The Regulator shall:-
• Grant rights of use for all national numbering resources for all publicly
available electronic communications services (subject to ensuring the
proper management of the national numbering scheme in accordance with
ComReg’s objectives under section 12 of the Act of 2002 and [Framework]
Regulation 16).
35
Framework Regulations (SI No. 333 of 2011)
Page 26 of 39Addressing Machine-to-Machine Communications ComReg 13/33
• Do so in a manner that gives fair and equitable treatment to all
undertakings providing publicly available electronic communications
services (subject to ensuring the proper management of the national
numbering scheme).
• Establish objective, transparent and non-discriminatory procedures for
granting rights of use for national numbering resources.
• Ensure that adequate numbers and numbering ranges are provided for all
publicly available electronic communications services.
• Subject only to limitations which may be specified by the Minister on the
grounds of national security, from time to time publish the details of the
national numbering scheme and significant subsequent additions or
amendments to it.
A1.9. Furthermore Regulation 13(2) of the Authorisation Regulations states that
“The Regulator shall establish open, transparent, non-discriminatory and
proportionate procedures for the grant of rights of use for numbers and shall
cause any such procedures to be made publicly available.”
A1.10. The National Numbering Conventions (currently ComReg 11/17) is ComReg’s
main vehicle for setting out the framework for management and use of
numbering resources and for making its procedures open and transparent,
while the Numbering Applications Procedures (currently described in ComReg
11/18) inform potential number users of how to apply for numbers and it
provides them with formats for that purpose.
Public Consultations
A1.11. Under Framework regulation12, where ComReg “intends to take a measure in
accordance with the specific regulations or intends to provide for restrictions in
accordance with Regulation 17(3) and (5), which have a significant impact on
a relevant market, the Regulator shall … publish the text of the proposed
measure, give the reasons for it, including information as to which of the
Regulator’s statutory powers gives rise to the measure, and specify the period
within which submissions relating to the proposal may be made by interested
parties”. … The Regulator may then, having considered any representations
received, take the measure with or without amendment.
A1.12. ComReg’s obligation to ensure the existence of adequate numbers and
numbering ranges is described at A1.7 and A1.9 above, whereas its powers
regarding rights of use for numbers in this context derive from Authorisation
Page 27 of 39Addressing Machine-to-Machine Communications ComReg 13/33
Regulations 13 and 14. The latter are implemented in the National Numbering
Conventions, as described in A1.9 above.
A1.13. ComReg does not believe that meeting its obligation to provide adequate
numbers – which clearly also applies to numbers for M2M purposes - through
the medium of new dedicated number ranges (i.e. as against requiring
existing ranges to be used) will “have a significant effect on a relevant
market”. Indeed it may be considered a prudent step to meet ComReg’s other
obligations of efficient and effective management of the numbering scheme.
A1.14. Nevertheless, ComReg is keen to seek the views of industry and consumers
on the specific approaches it proposes to take to M2M numbering, with the
aim of adopting the most effective approach possible, and with the widest
consensus. The proposed amendments to the National Numbering
Conventions to cover these changes can also conveniently undergo
consultation during this process.
Tariffs and Access
A1.15. The setting down of formal retail tariff ceilings by ComReg and its predecessor
the ODTR goes back to the first version of the National Numbering
Conventions in 2000, though de facto tariff ceilings already existed before the
ODTR was set up. Since 2002, the underpinning legislation has been
Regulation 14(1) and its Condition C1 of the Schedule to the Authorisation
Regulations, published that year.
A1.16. The current Regulation 14(1) (“Conditions attached to rights of use for
numbers”) states that: “The Regulator shall, as soon as practicable after the
commencement of these Regulations, specify conditions to be attached to a
right of use for numbers only as are listed in Part C of the Schedule.”
Condition C1 of Part C then states that [a condition which may be attached to
rights of use for numbers is] “Designation of service for which the number
shall be used, including any requirements linked to the provision of that
service and, for the avoidance of doubt, tariff principles and maximum prices
that can apply in the specific number range for the purpose of ensuring
consumer protection in accordance with section 12(2)(c)(ii) of the Act of
2002.”
A1.17. Machine-to-Machine communications, by definition, do not (normally) directly
affect consumers and it will usually be the case that consumers – even for
calls to machines within the home – will remain unaware of the telephone
numbers set up during the installation phase to receive those M2M calls. For
that reason, when ComReg carries out its duty under Regulation 14(1) to set
conditions of use for M2M numbers, it should in most cases avoid setting
Page 28 of 39Addressing Machine-to-Machine Communications ComReg 13/33
pricing conditions designed to ensure consumer protection. It is also the case
that operators are already very aware that the success of M2M
communications depends critically upon very low charges, and if they are to
negotiate effectively to be the carriers of such services then they need to
support those existing pricing practices of the marketplace. The self-interest
motivation should therefore obviate any need to intervene regarding retail
prices.
A1.18. Wholesale pricing for M2M is best left to the marketplace to resolve, with the
regulator only stepping in if development of M2M is being stunted nationally
through unreasonable or discriminatory practices. In the event that such a
situation arises, it would be incumbent upon ComReg to examine compliance
vis-à-vis (inter alia) the Access Regulations and – if relevant – to examine the
details of any disputes that might be brought to its attention.
Page 29 of 39Addressing Machine-to-Machine Communications ComReg 13/33
Annex: 2 NRAs which have developed
an M2M policy
A2.1. ComReg is aware of initiatives already taken by some other European NRAs
with respect to M2M, though generally this has been limited to providing
numbering resources for M2M purposes. The known list is as follows;
M2M Numbering
Country Description of approach Policy introduced
Policy?
Non-geographic, fixed-mobile agnostic
Belgium Yes 01-Oct-2012
network code, dedicated to M2M.
IMSI only identifier to be used for M2M.
Denmark Yes 01-Dec-2009
No dedicated number range specified.
Finland Yes Awaiting further details. Not known
Luxembourg Yes Awaiting further details. Not known
Netherlands Yes Dedicated M2M number ranges for mobile. 01-Dec-2011
Norway Yes Dedicated M2M number ranges for mobile. Pre-2009
Spain Yes Dedicated M2M number ranges for mobile. 01-Apr-2012
Separate dedicated M2M number ranges for
Sweden Yes Pre-2011
fixed and for mobile.
A2.2. The numbering details applicable to those initiatives are as follows:
Country Code Serial Code Total
Country Code Block Size Max Blocks
Code Type Digit Length Allocation
Belgium 32 NDC 11 11 100 billion 1 million 10,0000
Denmark 45 MNC n/a 6 n/a Not known n/a
Netherlands 31 MNC 97 11 100 billion Not known n/a
Norway 47 MNC 59 6 1 million 10,000 100
Spain 34 MNC 59 11 100 billion Not known n/a
MNC 719 10 10 billion Not known n/a
Sweden 46 NDC 378 10 10 billion Not known n/a
Page 30 of 39Addressing Machine-to-Machine Communications ComReg 13/33
Annex: 3 Proposed Changes to
National Numbering Conventions
Proposed New and/or Amended Text
A3.1. If, following this consultation, ComReg concludes that a new number range for
M2M should be introduced as soon as possible, it will introduce new text to
the National Numbering Conventions (NNC) and related documents along the
following lines:
Amendment of National Numbering Conventions
A3.2. Section 8.1 “The rights of Authorised Persons to numbers/ number blocks” will
be amended to the following:
3 Except as otherwise indicated herein, and/or for efficient management purposes, primary
allocation or reservation of most numbering resources is made only to (authorised)
undertakings (network operators or certain service providers), who are then responsible
for carrying out secondary allocation in accordance with these Conventions;
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